2 Specifically brought to our atte ntion were the following:

 There are many structures other than buildings that are vulnerable to commensal rodent

infestations.

Beginning in early 2011, it was brought to the Ag ency’s attention that the restriction that

commensal use rodenticides be used within “50 feet of buildings” would leave professional pest applicators poorly equipped to deal with commensal rodent infestations in many important sites. At certain sites such as food processing and storag e facilities, it is importa nt to make rodenticide bait placements farther than 50 feet to create a pr otective perimeter against commensal rodents or to protect non-building structures that store food farther than 50 feet from buildings. Ports, which may contain many storage and transport units but lack buildings, were al so given as another example of areas that require rodenticides to protect sensitive resources more than 50 feet from buildings.

Because of this, the Agency will change the term “ building” to “man-made structures constructed in

a manner so as to be vulnerable to commensal r odent invasions and/or to harboring or attracting

rodent infestations.”

 The importance of placing dumpsters and other ga rbage receptacles farther than 50 feet from buildings and the utility of usi ng rodenticides around dumpsters.

IPM guidance informs building and pest managers to locate dumpsters and other waste receptacles as far from the resource they are trying to protect from rodents as possible. The Agency has been made aware of several municipa l guidance publications that sugge st commercial waste enclosures be sited more than 100 feet from buildings (S anta Barbara Handout). Also, placing dumpsters

farther than 50 feet from buildi ngs (especially those involved in food production or processing) can aid in the management of flies and other simila r pests. (UGA Extension and Illinois Dept of Health)

 Outdoor food storage facilities that are farther than 50 feet from buildings.

The California League of Food Pro cessors submitted comments informing the Agency that some of their members store finished tomato paste in seal ed containers outdoors, mo re than 50 feet from buildings. The tomato paste is stor ed farther than 50 feet to accomm odate facility vehicle traffic. According to their comments, the 50-foot restric tion would lead to diffi culty controlling rodent populations around the stored food product therefore making complian ce with food safety standards very difficult. (See June 7, 2011 Letter Neenan to Keigwin).

 In urban areas, rat infestations often occu r farther than 50 feet from buildings.

The New York City Department of Health and Mental Hygiene (DOHMH) cited several examples in urban areas where standard rodent control pr actices and IPM methodology require rodent control farther than 50 feet from buildings. These exam ples include trash recep tacles, parks and green space as well as urban sewage cat ch basins which are located fart her than 50 feet from buildings. (See letter Mario Merlino, New York City Department of Health and Mental Hygiene to US EPA, June 9, 2011)3 After carefully analyzing these comments, and in consideration of the Agency’s efforts to reduce wildlife exposures, PRD has determined that it w ould be appropriate to revise the labels for professional use commensal rodenticide products to provide applicators with some additional flexibility to meet critical pest control needs. This additional flexib ility (i.e., extending the distances from man-made structures) is balanced with specific label requirements for integrated pest management practices, specific placement instruc tions, and prohibitions on certain use practices.

 Burrow baiting with place packs and blocks is risky and should be reconsidered

The Ad Hoc Rodenticide RMD Stakeholder Workgr oup also brought to the Agency’s attention the issue of burrow baiting applica tions made with place packs a nd blocks. According to the Workgroup, it supports the Agency prohibiting burro w applications with rodenticide place packs and blocks because doing so “addresses and corrects the most environmentally insensitive and risky practice of stuffing packets and blocks down rat hol es (as often they come right back up and thus present direct exposure to pets , children, wildlife mamm als and birds, environmental wash off, etc.).” The Agency agrees with the Workgr oup and will implement this restriction. (See presentation Ad Hoc Rodenticide RMD Stakeholder Workgroup , August 30, 2011)

New Restrictive Language

The new label perimeter restriction for profession al use commensal rodenticide products is as

follows:

 “Use Restrictions”

o on all professional labels: “This product can only be used to control Norway rats, roof rats, and house mice in and

within 100 feet of man-made structures constr ucted in a manner so as to be vulnerable to

commensal rodent invasions and/ or to harboring or attracting rodent infestations. Examples

of such structures include homes and othe r permanent or temporary residences, food processing facilities, industrial and commercial buildings, trash receptacles, agricultural and public buildings, transport vehicl es (ships, trains, aircraft), docks and port of terminal buildings and related structures around and associated with thes e sites. Fence and perimeter baiting, beyond 100 feet from a structure as defi ned above, is prohibited. This product must not be applied directly to food or feed crops.”

o on all agricultural labels: “This product can only be used to control Norway rats, roof rats, and house mice in and within 100 feet of agricultural buildings and man-made agricultu ral structures constructed in

a manner so as to be vulnerable to commensal rodent invasions and/or to harboring or attracting rodent infestations. Fence a nd perimeter baiting, beyond 100 feet from an agricultural structure as defi ned above, is prohibited. This product must not be applied directly to food or feed crops”4  Label language specific to block, so ft bait, and sachet formulations

“Burrow baiting with <insert product name> is prohibited.”

 On all first-generation anticoagulants and non- anticoagulants professional and agricultural products labeled for applicat ion in rodent burrows:

“This product may only be applied to active rode nt burrows to control Norway rats, and roof rats beyond 100 feet, provided that infestations of the Norway rat or roof rat have been confirmed. Bait must be placed no less than 6 inches into active Norway/roof rat burrows. Because Norway/roof rat infestations may o ccur in areas farther than 100 feet from buildings and man-made structures when the r odents have ample supplies of food and cover,

efforts should be made to remove conducive food trash, garbage, clutter, and debris. Do not

broadcast bait.”

This label language will only apply to commensal use rodenticide products that are marketed to occupational (agricultural and PCO) users and sold in quantities of four pounds or greater (depending on the active ingredient). All homeowner products will continue to be subject to the 50 foot restriction per the RMD.

If you have any questions or commen ts, please contact Rusty Wasem at wasem.russell@epa.gov or 703-305-6979.

Guidance Consulted for Integrate Pest Mana gement Practices for Dumpster and Refuse

The City of Santa Barbara Department of Public Works. Space Allocation Guide for Trash and Recycling For New Commercial: Construction and Remodel

. http://www.santabarbaraca.gov/Documents/Fo rms_and_Handouts/Public_Works/03_Guides /Trash_and_Recycling_Space_Allocation_Guide.pdf

The District of Columbia Health Regulation a nd Licensing Administration, Bureau of Community Hygiene. Using Dumpsters to Prevent Rodent Problems

. http://hrla.doh.dc.gov/hr la/cwp/view,a,1384,q,572974.asp

Extension. Structural and Public Health Pests: Flies (House Flies, Filth Flies)

. http://www.extension.org/pages/ 23627/structural-and-public-hea lth-pests:-flie s-house-fliesfilth-flies Illinois Department of Public Health. Prevention & Control: The House Fly and Other Filth Flies

. http://www.idph.state.il.us /envhealth/pcf ilthflies.htm